Human Resources Policies
POLICY: CODE OF CONDUCT
POLICY NUMBER: OGC-5
Effective Date: November 11, 2004
Revisions: February 1, 2007, September 2007
Responsible Officer: Senior Vice President and General Counsel
Table of Contents
Preamble
Code of Conduct
Principle 1. Legal Compliance
Standards
1.1 Public Purpose/Non-Profit Status
1.2 Lobbying/Political Activity
1.3 Environmental
1.4 Discrimination
1.5 Criminal Laws
Principle 2. Personal Relationships
Standards
2.1 Relationships with Students
2.2 Relationships between Employees
2.3 Relationships with Patients
Principle 3. Business Ethics
Standards
3.1 Honest Communication
3.2 Proper Use of Proprietary Information
3.3 Ethical Dealings
Principle 4. Confidentiality
Standards
4.1 Education Records
4.2 Personnel Actions/Decisions
4.3 Proprietary Information
4.4 Patient Information
4.5 Financial Information
Principle 5. Conflicts of Interest
Standards
5.1 Outside Financial Interests
5.2 Services for Competitors/Vendors
5.3 Participation on Boards of Directors or Trustees
5.4 Honoraria
Principle 6. Business and Professional Relationships
Standards
6.1 Gifts and Gratuities
6.2 Workshops, Seminars and Training Sessions
6.3 Use of Non-Public Information
6.4 Business Inducements
6.5 Alumni/ae and Other Supporters of the University
Principle 7. Protection of Assets
Standards
7.1 Internal Controls
7.2 Financial Reporting
7.3 Travel and Entertainment
7.4 Personal Use of University Assets
Administration and Application of this Code of Conduct
Directory of Referenced Officers
PREAMBLE
All members of the Drexel University Community - students, faculty, employees, and members of the Board of Trustees - share responsibility for the welfare of the institution. That obligation extends not just to the institution, but to all other parts of the enterprise. Unique in our society, university communities depend in significant measure upon the integrity, honesty, good citizenship and professional conduct of their members.
Universities are also unique in requiring for their success a spirit of open and free inquiry, of pluralism, of creativity and of appreciation and respect for difference.
Just as all citizens enjoy certain freedoms and owe certain responsibilities to society at large, so too do those who benefit from their relationship with the Drexel University community owe obligations to it. Those obligations can be broadly summarized as follows:
Legal Compliance: The University and its citizens will strive to ensure that all activity conducted by, at, or on behalf of the institution is in full compliance with the law and the official policies of the institution.
Confidentiality: The University and its citizens shall strive to ensure the confidentiality of any information given to it in trust, in accordance with applicable ethical and legal, professional and legal standards.
Respect for Difference: The University and its citizens will maintain an atmosphere welcoming to individual and social diversity in which ethnic differences, gender differences and intellectual differences are respected by others and treated as a valuable addition to and part of the intellectual and cultural life of the University.
Intellectual Integrity: The University shares a commitment to all others, and to society at large, to engage in the educational mission of the University in the sprit of free and open inquiry and with both personal and intellectual honesty and integrity.
Administrative Integrity: Those who are charged with responsibility for conducting the affairs of the University and administering its policies, programs, and divisions must perform their duties in a fair, honest, and consistent fashion, without regard to their personal preferences, biases or prejudices.
Business and Professional Ethics: Those who are part of the University community are representatives of the University, whether or not intending to be so; and as representatives they must comport themselves in accordance with the ethical standards of their business or profession, and not engage in any activity or scheme intended to deprive anyone unfairly of money, property, or services.
Business Relationships: The University and any of its citizens who are in a position of conducting business transactions with vendors, contractors and other third parties on behalf of the University shall not accept gifts or favors, or solicit such gifts or favors, or other improper inducements in exchange for exercising influence or providing assistance in a business transaction affecting the University.
Conflicts of Interest: The University and its citizens will not use their position or membership in the community to profit personally or to assist others in profiting in any way at the expense of the organization.
Protection of Assets: The University and its citizens will strive to preserve, protect, and enhance the University's assets by making prudent and effective use of University resources and property and by accurately reporting its financial condition.
These obligations, owed by each of us to each of us, are more fully described in the following Code of Conduct, which was created by a University Advisory Committee comprised of faculty, staff, and administrators in May 2003, submitted to the University community for comment, and approved by the Board of Trustees in December 2003.
Because this Code is available on the University's website, all members are encouraged to review it whenever they believe that they are, or might find themselves to be, in a situation where their actions might reflect poorly on the University, its integrity, its mission, its responsibilities to its students and patients, its standing, or its reputation; and to seek guidance from the Office of the General Counsel (hereinafter collectively referred to as “University Counsel”) or the Chief Compliance Officer.
CODE OF CONDUCT
This Code of Conduct contains Principles articulating the policy of the organization and Standards, which are intended to provide additional guidance to persons functioning in managerial or administrative capacities. The Principles set forth in this Code of Conduct shall be distributed when adopted by the Board of Trustees to all members of the University community. New members of the University community shall receive a copy at the beginning of their employment or term of office. Supervisors shall review the terms of the Code of Conduct with their employees when appropriate.
All members of the University community are responsible for ensuring that their behavior and activity are consistent with the Code of Conduct as well as University policies and procedures, and applicable federal, state and local laws and regulations, and professional standards (hereinafter collectively referred to as “Applicable Rules”).
As used in this Code of Conduct, the term the “University” is meant to include the whole of the university: each of its colleges, schools, divisions, subsidiaries, operating and business units, its administration, its boards of advisors, and its Boards of Trustees.
The terms “officer,” “faculty,” “trustee,” “employee,” “agent” and “student,” include any person who fills such a role or provides services on behalf of any part of that whole University. The term “student” refers to any student enrolled in the University whether graduate or undergraduate, full-time or part-time.
If any member of the University community believes that these standards are not being honored, the member should notify a supervisor, a member of the faculty, or a Senior Vice President of the University, or call or log on to the University's confidential hotline:
866-358-1010 (toll free)
or
https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=14030
Principle 1 - Legal Compliance
The University will strive to ensure that all activity by or on behalf of the organization is in compliance with Applicable Rules.
The following Standards are intended to provide guidance to members of the University community to assist them in their obligation to comply with Applicable Rules. These standards are neither exclusive nor complete. Members of the University community are required to comply with all Applicable Rules, whether or not specifically addressed in these policies. If questions arise regarding the existence, interpretation, or application of any law, they should be directed to the Chief Compliance Officer or University Counsel.
Standard 1.1 – Public Purpose/Non-Profit Status
As a non-profit entity, the University has a legal and ethical obligation to act in compliance with applicable laws, to engage in activities in furtherance of its charitable purpose, and to ensure that its resources are used in a manner which furthers the public good rather than the private or personal interests of any individual. Consequently, the University and members of the University community will avoid compensation arrangements in excess of fair market value, will accurately report financial matters to appropriate taxing authorities, and will file all tax and information returns in a manner consistent with applicable laws. All members of the University community will use their best efforts not to waste University resources, and to use them to their most efficient purposes.
Standard 1.2 – Lobbying/Political Activity
While the University encourages its members to be engaged in civic life, the University expects each member of the University community to refrain from engaging in activity which may jeopardize the tax-exempt status of the organization, including lobbying and political activities.
1. No member of the University community at the University's expense may make any agreement to contribute any money, property or services of any member of the University community to any political candidate, party, organization, committee, or individual in violation of any Applicable Rule. As private citizens, members of the University community are entitled to participate in and contribute to political organizations or campaigns, but they must do so as individuals, not as representatives of the University, and they must use their own funds, without reimbursement.
2 Where its experience may be helpful, the University may publicly offer recommendations concerning legislation or regulations being considered. In addition, it may analyze and take public positions on issues that have a relationship to the operations of the University when the University's experience contributes to the understanding of such issues. Such activities further the purpose of the University and demonstrate its commitment to the public good.
3. The University has many contacts and dealings with governmental bodies and officials. All such contacts and transactions shall be conducted in an honest and ethical manner in accordance with all Applicable Rules. Any attempt to influence the decision-making process of governmental bodies or officials by an offer of any benefit is absolutely prohibited. Any requests or demands by any governmental representative for any benefit should be immediately reported to the General Counsel.
Standard 1.3 – Environmental
It is the policy of the University to manage and operate its business in the manner which respects our environment and conserves natural resources. Members of the University community will strive to utilize resources appropriately and efficiently, to recycle where possible and shall handle all hazardous materials and dispose of all waste in accordance with applicable laws and regulations, and to work cooperatively with the appropriate authorities to remedy any environmental contamination for which the University may be responsible.
Standard 1.4 – Discrimination
The University believes that the fair and equitable treatment of members of the University community, patients, and other persons is essential to fulfilling its mission, vision and goals.
It is a policy of the University to provide its services without regard to the race, color, religion, sex, sexual preference, ethnic origin, age, or disability of such person, or any other classification prohibited by law.
It is a policy of the University to recruit, hire, train, promote, assign, transfer, layoff, recall, and terminate members of the University community based on their own ability, achievement, experience and conduct without regard to race, color, religion, sex, sexual preference, ethnic origin, age, disability, or any other classification prohibited by law.
The University welcomes diversity, and honors its Founders' vision through its policies of inclusion and respect for differences. No form of harassment or discrimination on the basis of sex, race, color, disability, age, religion, sexual preference, ethnic origin, disability, or any other classification prohibited by law will be permitted. Any allegation of harassment or discrimination will be promptly investigated in accordance with applicable University policies.
See:
HR-1 Affirmative Action and Equal Opportunity Policy
HR-2 Non-Discrimination/Reasonable Accommodation of Individuals with Disabilities
HR-3 Harassment Policy
HR-4 Discrimination or Harassment Complaint Resolution Procedure
Standard 1.5 – Criminal Laws
The University expects that members of the University community shall not violate any criminal laws.
Principle 2 – Personal Relationships
A core principle of any university is respect for personal dignity. While the University will respect the privacy of its members, it recognizes that there exists the opportunity for the inappropriate use of power, trust or authority, of a teacher over a student, of a supervisor or administrator over an employee, or of a physician over a patient. Abuse of such power will not be tolerated, and the appearance of impropriety must be avoided.
Standard 2.1 – Relationships with Students
Students of all levels of age and maturity come to the University to learn. The special relationships they are able to form with members of the faculty are the best of what a University can offer. Such close academic relationships, however, are susceptible to being misconstrued as inviting social or sexual relationships, or to suggesting to others that such a relationship might exist. It is prohibited for any employee of the University to have a romantic or sexual relationship with a student who is a minor or an undergraduate student of any age who is subject to that employee's direct or indirect authority or control (that is, anywhere within the chain of academic responsibility for that student, from advisor or teacher, through department head, school director or dean, and provost).
Romantic and sexual relationships between adult graduate students and University employees are strongly discouraged and must be entered into with great sensitivity to the potentials for misperception and abuse; if they exist, they must be immediately disclosed in accordance with University policy, and the employee must immediately removed from any direct or indirect responsibility, authority or control, real or perceived, over the student.
Standard 2.2 – Relationships between Employees
The University recognizes that it asks much of its employees, and that those who give the most often find themselves enjoying personal relationships with other employees. When the employees are at the same level in the organization and in different units or departments, the opportunities for friction are minimized; but where they work together, and especially where one works for another, the opportunity arises for real or perceived conflicts of interest. Romantic, sexual or familial relationships between employees in the same administrative unit or department are strongly discouraged and must be entered into with great sensitivity to the potentials for misperception and abuse; and if they exist, they must be immediately disclosed in accordance with University policy and the employees separated (physically or organizationally), so that one does not have any direct or indirect responsibility, authority or control, real or perceived, over the other. Any and all steps taken to eliminate any real or potential authority or control one employee has over the other must be set forth in writing by the applicable senior administrator and filed in both employees’ personnel files.
See:
HR-5 Personal Relationships
HR-46 Nepotism/Employment of Relatives
Standard 2.3 – Relationships with Patients
Romantic and sexual relationships between health care providers and current patients are prohibited. Romantic or sexual relationships with former patients are strongly discouraged because they may be unduly influenced by the previous physician— patient relationship. Such relationships should be entered into only with extreme caution and sensitivity. Before embarking upon such a relationship, the health care professional must ensure that the professional/patient relationship has ceased, that the patient has an alternate health care provider, and that the applicable ethics and codes of conduct of the profession are fully observed.
Principle 3 – Business Ethics
In furtherance of the University's commitment to the highest standards of business ethics and integrity, members of the University community will accurately and honestly represent the University and will not engage in any activity or scheme intended to defraud or unfairly deprive anyone of money, property, or services.
The Standards set forth below are designed to provide guidance to ensure that the University's business activities reflect the highest standards of business ethics and integrity. The conduct of members of the University community not specifically addressed by these standards must still be consistent with Principle 2.
Standard 3.1 – Honest Communication
The University requires candor, honesty, and cooperation from individuals in the performance of their responsibilities and in communication with our attorneys, auditors and consultants. No member of the University community shall make false or misleading statements to any patient, student, employee, law enforcement official, or person or entity doing business (or seeking to do business) with the University.
Standard 3.2 – Proper Use of Proprietary Information
Members of the University community shall not misappropriate confidential or proprietary information belonging to another person or entity nor utilize any publication, document, computer program, information, idea or product in violation of another person's or entity's interest in or rights to such property. All members of the University community are responsible to ensure they do not improperly copy or use documents or computer programs in violation of applicable copyright laws or licensing agreements.
Members of the University community shall not utilize confidential business or scientific information obtained from competitors or other parties, including customer lists, price lists, contracts or other information, in violation of prior employment agreements, nondisclosure or confidentiality agreements, or in any other manner likely to provide an unfair competitive advantage to the University.
See:
Conduct of Research Policy, Part VI, Peer Review and Privileged Information
Acceptable Use Policy
Standard 3.3 – Ethical Dealings
In addition to this Code of Conduct, professional employees of the University are obligated to perform their duties in full compliance with the codes of conduct that apply to their professions. In addition, certain departments (Finance/Treasurer's Office and Institutional Advancement) have adopted detailed codes of conduct that apply more particularly to the functions they perform; and those codes also must be followed.
See: Principle 5 – Business and Professional Relationships – below.
Principle 4 – Confidentiality
All members of the University community shall strive to maintain the confidentiality of all confidential information in accordance with applicable legal and ethical standards.
Members of the University community are in possession of and have access to a broad variety of confidential, sensitive and proprietary information, the inappropriate release of which could be injurious to individuals, affiliated institutions and parties with which the University does business, and the University itself. Each member of the University community has an obligation to actively protect and safeguard confidential, sensitive and proprietary information in a manner designed to prevent the unauthorized disclosure of information.
See: HR-50 Confidentiality
Standard 4.1 – Educational Records
Student educational records will be maintained in accordance with all Applicable Rules. Students of the University who have reached the age of 18 have the right to inspect and review their own educational records. Generally, the University may not disclose information contained in education records without the student's written consent or legal process. If questions arise regarding an obligation to maintain the confidentiality of information or the appropriateness of releasing information, members of the University community should seek guidance from business unit management, the Registrar (who serves as the University's Family Educational Rights and Privacy Act Officer (“FERPA Officer”), or University Counsel.
See:
Family Educational Rights and Privacy Act Policy
Family Educational Rights and Privacy Act Guidelines
Standard 4.2 – Personnel Actions/Decisions
Salary, benefit and other information relating to the employment of members of the University community shall be treated as private and confidential. Personnel files, payroll information, disciplinary matters, and similar information shall be maintained in a manner designed to ensure confidentiality in accordance with applicable laws. Members of the University community will exercise due care to prevent the release or sharing of information beyond those persons who may need such information to fulfill their job function, and shall give notice to the employee if any confidential information is required to be given to third parties.
Standard 4.3 – Proprietary Information
Information, ideas and intellectual property assets of the University are important to organizational success. Information pertaining to the University's competitive position or business strategies, payment and reimbursement information, trade secrets, research, inventions, and information relating to negotiations with members of the University community or third parties should be protected and shared only with members of the University community having a need to know such information in order to perform their job responsibilities. Members of the University community should exercise care to ensure that intellectual property rights, including patents, trademarks, copyrights, and software, are carefully maintained, preserved and protected.
See:
Copyright Policy
Patent Policy
Conduct of Research Policy
Standard 4.4 – Patient Information
| 
